KVKK Disclosure Notice

Your personal data is processed by the legal entity identified below, acting in the capacity of data controller under Turkish Law No. 6698 on the Protection of Personal Data (KVKK):

Company Name: BLACK REIN TEKNOLOJİ A.Ş.

Address: Teknopark İstanbul, Pendik/İstanbul

Email: info@ihracatabasla.com.tr

KVKK Inquiries Email: kvkk@ihracatabasla.com.tr

Web: ihracatabasla.com.tr

Your personal data is processed in accordance with the data processing conditions set forth in Articles 5 and 6 of Turkish Law No. 6698 on the Protection of Personal Data (KVKK), for the following purposes:

Execution and improvement of the services provided through the İhracatAI platform.

Creation, management, and security of user accounts.

Delivery of AI-powered export analysis, customer matching, pricing, and market research services.

Processing of subscription and payment transactions.

Conducting communication activities and providing technical support.

Executing marketing and campaign activities (with explicit consent).

Fulfilling legal obligations and providing information to authorized public institutions and agencies.

Ensuring platform security, preventing fraud and misuse.

Conducting statistical analyses and reporting activities.

The following categories of personal data are processed within the scope of the Platform:

Identity Information: First name, last name, Turkish National ID number (where required), title.

Contact Information: Email address, phone number, company address.

Customer Transaction Information: Subscription details, payment history, service usage records, transaction history on the Platform.

Company Information: Company name, tax identification number, trade registry number, industry sector, export destination countries, product and service details.

Digital Footprint Information: IP address, browser information, operating system, session durations, click data, cookie data.

Marketing Information: Campaign preferences, communication permissions, survey responses.

Your personal data may be transferred to the following parties in accordance with the conditions set forth in Articles 8 and 9 of the KVKK:

Domestic Transfers:

To authorized public institutions and agencies within the framework of legal obligations.

To payment service providers for the purpose of processing payment transactions.

To law firms and legal consultants for the conduct of legal proceedings.

International Transfers:

For the operation of AI-powered features on the İhracatAI platform, a portion of your data may be transferred to AI service providers located abroad (such as OpenAI, Anthropic, etc.). This transfer is based on your explicit consent under Article 9 of the KVKK.

Transfers to international server providers may be made for the purpose of delivering cloud infrastructure services.

For international data transfers, the requirement of adequate protection in the destination country or a commitment by the data controller to provide adequate protection shall apply.

Your personal data is collected through the following methods:

Electronically, during the registration and transactions you carry out on the Platform.

Through contact forms, email correspondence, and phone calls.

Automatically, by means of cookies and similar technologies.

Through third-party integrations (such as social media login).

Your personal data is processed based on the following legal grounds:

Your explicit consent (KVKK Art. 5/1).

Being directly related to the establishment or performance of a contract (KVKK Art. 5/2-c).

Fulfillment of the data controller's legal obligation (KVKK Art. 5/2-d).

Legitimate interest of the data controller (KVKK Art. 5/2-f).

Pursuant to Article 11 of the KVKK, as a data subject you have the following rights:

a) The right to learn whether your personal data is being processed.

b) The right to request information about the processing of your personal data if it has been processed.

c) The right to learn the purpose of processing your personal data and whether it is being used in accordance with that purpose.

d) The right to know the third parties to whom your personal data has been transferred, whether domestically or internationally.

e) The right to request correction of your personal data if it has been processed inaccurately or incompletely.

f) The right to request deletion or destruction of your personal data under the conditions set forth in Article 7 of the KVKK.

g) The right to request that operations carried out pursuant to paragraphs (e) and (f) be notified to third parties to whom your personal data has been transferred.

h) The right to object to a result that is to your detriment arising from the exclusive analysis of your processed data through automated systems.

i) The right to claim compensation for damages incurred due to the unlawful processing of your personal data.

You may exercise your rights under the KVKK through the following methods:

Email Application: You may submit your request to kvkk@ihracatabasla.com.tr, with the subject line "KVKK Information Request."

Written Application: You may submit your application via registered mail to the address "Teknopark İstanbul, Pendik/İstanbul," accompanied by documents verifying your identity.

Applications must include the following information:

First name, last name, and signature if the application is in writing.

Turkish National ID number (passport number for foreign nationals).

Residential or business address for notification purposes.

Email address and phone number for notification, if available.

Subject of the request.

Applications will be responded to free of charge within a maximum of 30 days. If the process entails an additional cost, the fee determined by the Personal Data Protection Board may be charged.

Your personal data is retained for the duration required by the purposes of processing and within the statute of limitations prescribed by applicable legislation:

Account Information: For the duration that the account remains active, and for 3 years following account closure.

Transaction Records: For 2 years pursuant to Law No. 5651.

Payment Information: For 10 years pursuant to the Turkish Commercial Code No. 6102 and the Tax Procedure Law No. 213.

Marketing Permissions: Until the permission is withdrawn.

Cookie Data: Between the session duration and 2 years, depending on the type of cookie.

Personal data for which the retention period has expired is deleted, destroyed, or anonymized in accordance with Article 7 of the KVKK and the relevant regulatory provisions.